Privacy policy
1. Introduction and scope
This privacy policy aims to inform you about how Four & Five Law BV (“Four & Five”, “we”, “us”) collects and processes your personal data via our website (the “Website“) and in the course of our (client) relationship.
Four & Five respects your privacy and is committed to protecting your personal data and your privacy in accordance with Belgian and European data protection laws, including the EU General Data Protection Regulation 2016/679 (“GDPR”) as well as any applicable national implementing and supplementing laws. Please read this privacy policy carefully. It describes not only your rights, but also the way in which you can exercise these rights.).
Lees deze privacy policy zorgvuldig door.
Ze beschrijft niet alleen jouw rechten, maar ook de manier waarop je deze rechten kan uitoefenen.
By using our Website or by disclosing your personal data you acknowledge the manner in which Four & Five collects and processes your personal data as described in this privacy policy.
2. Who we are and how to contact us?
“Four & Five” refers to Four & Five Law BV, a limited liability company, existing under Belgian law, with office at Jan van Gentstraat 1/101, 2000 Antwerp, Belgium and with company number 0699.862.720. Four & Five acts as a data controller in respect of the personal data collected and processed via our Website and in the course of our (client) relationship.
If you have any questions about this privacy policy, your privacy and/or how we process your personal data, you can contact us by sending an email to: privacy@fourfive.be.
3. What personal data do we process?
We processes different types of personal data; this depends on the functionalities you use on our Website, the services you wish to use and on the personal data you share with us.
If we processes your personal data, it will be personal data of one of the categories listed below:
- Identification and contact details (such as name and first name, phone number, address, email address, contact message, etc.);
- Professional information (such as profession, company you work for, job title, (company) address, company registration and VAT number);
- Technical information (such as information about your computer, mobile and other devices (such as, your IP- address, user-ID, operating system, browser type);
- Usage information (such as information regarding your usage of our Website (such as, history, logs, date, time, location, frequency, duration of the pages you have viewed, consent preferences, information regarding consent(s) given by you (such as, the date and time of your consent));
- Any other categories of personal data as identified below under title 4.
In principal, your personal data originates from you directly or is automatically collected by us (in case of technical or usage information).
If you disclose any personal data of third parties to us, you guarantee that you have informed those third parties (if necessary under applicable laws) and you have the right to communicate the third parties’ personal data to Four & Five in accordance with applicable laws.
4. For which purposes do we process personal data, on which legal basis and for how long?
4.1 General
Depending on your use of the Website, our services, the information you share with us and our (client) relationship, Four & Five processes personal data for the purposes specified in this section 4 (if and to the extent applicable to your situation). Please note that our Website and services may evolve and more functionalities may be added from time to time. In such event, we will update the below table as necessary and your additional consent (if and to the extent required) shall be requested.
For certain processing purposes, Four & Five requires your consent. The consent you give is always free and you have the right to withdraw it at any time. Your withdrawal of consent does not affect the processing of personal data prior to such withdrawal or our processing activities which are based on any other legal basis. You can withdraw your consent by sending an email to: privacy@fourfive.be.
Het intrekken van jouw toestemming heeft geen invloed op de verwerking van persoonsgegevens voorafgaand aan deze intrekking of op verwerkingsactiviteiten die zijn gebaseerd op een andere rechtsgrond.
4.2 Website-users
Four & Five may process personal data of Website-visitors for the following purposes:
| Purpose | Type of personal data | Legal basis | Retention period |
| To manage and respond to your contact requests and questions submitted via the Website (such as after you have submitted a contact form). |
Identification and contact details Professional information Any feedback and information you choose to share with us during our contact |
Performance of a contract |
As long as necessary to contact you (with respect to a submitted contact request). Your identification and contact details will in any event be deleted no later than 3 years after our last contact. |
| Management and booking of appointments and other (online) meetings and to ensure a proper follow up (by sending related (background) information such as commercial offers). |
Identification and contact details Professional information Technical information Any feedback and information you choose to share with us during our meeting |
Legitimate interest or performance of a contract (as applicable) |
As long as necessary to contact you and manage our appointments and meetings. Your identification and contact details will in any event be deleted no later than 3 years after our last contact. |
| To improve our Website, your user experience thereof and our service offering in general by gathering technical, analytical and statistical insights. |
Technical information Usage information Any feedback you choose to provide us |
Consent (as given via the cookie banner on our Website). The consent you give is always free. You have the right, at any time and free of charge, to withdraw your consent, by sending an email to: privacy@fourandfive.be. |
The retention period varies from as long as the duration of a Website-visit, to as long as your consent is not withdrawn (as applicable). Technical information, will in any event be pseudonymized or deleted (i) upon your withdrawal of consent; and (ii) within a reasonable time after the collection of the data. For more details, reference is made to our cookie policy. |
| To register your participation to any of our events, workshops or academies and to organize our events, workshops and academies. |
Identification and contact details Professional information Technical information As long as necessary to organize the relevant event, workshop or academy. |
Performance of a contract | As long as necessary to organize the relevant event, workshop or academy. |
| For direct marketing purposes (such as to send promotional emails about our services, functionalities, special offers, events and other information which we think might interest you). |
Identification and contact details Professional information Technical information Usage information |
Consent or legitimate interest (as applicable) The consent you give is always free. You have the right, at any time and free of charge, to withdraw your consent and to object to the processing of your personal data for direct marketing purposes, by sending an email to: privacy@fourfive.be. |
As long as your consent is not withdrawn. For more details, reference is made to our cookie policy. |
4.3 Applicants
Four & Five may process personal data of applicants for the following purposes:
| Purpose | Type of personal data | Legal basis | Retention period |
| To carry out recruitment and selection activities for open positions at Four & Five. |
Identification and contact details Professional information Any documents and information you choose to share with us during your application (such as CV, cover letter, education, experience, etc.).
|
Legitimate interest or performance of a contract (as applicable) | Up to 5 years after notifying the last candidate that he/she is not retained for the job, unless a longer retention term applies in accordance with this privacy policy. |
| To create a talent pool for future vacancies and recruitment purposes. |
Identification and contact details Professional information Any documents and information you choose to share with us during your application (such as CV, cover letter, education, experience, etc.). |
Consent The consent you give is always free. You have the right, at any time and free of charge, to withdraw your consent, by sending an email to: privacy@fourandfive.be. |
Up to 5 years after obtaining your consent. Your personal data will in any event be deleted in the event you withdraw your consent. |
4.4 Clients
Four & Five may process personal data of clients for the following purposes:
| Purpose | Type of personal data | Legal basis | Retention period |
| To provide and execute our legal services. |
Identification and contact details Professional information Payment details Any other information you choose to share with us during our consultations or in the execution of our services |
Performance of a contract |
As long as necessary for the execution of our services and client relationship. Your personal data will in any event be deleted ten (10) years after the expiry or termination of our client relationship, unless a longer retention term applies in accordance with applicable laws or deontological rules to which we are subject. |
|
Onboarding of new clients to adhere to our anti-money laundering and know-your-customer obligations. For more information about certain of our legal obligations please consult our general terms and conditions. |
Identification and contact details Professional information Payment details Information regarding your visit and appointments (e.g. date and time) National registry number (or similar identification number) |
Legal obligation or performance of a contract (as applicable) | Up to ten (10) years after the expiry or termination of our (client) relationship, unless a longer retention term applies in accordance with applicable laws or deontological rules to which we are subject. |
| To manage our client relationship (including to answer your questions and requests and to follow up on meetings and appointments). |
Identification and contact details Professional information Any feedback and information you choose to share with us during our contact |
Legitimate interest |
As long as necessary for the execution of our client relationship and in any event as long as necessary to contact you. Your identification and contact details will in any event be deleted no later than ten (10) years after the expiry or termination of our (client) relationship, unless a longer retention term applies in accordance with applicable laws or deontological rules to which we are subject. |
| To review your feedback and improve your customer experience and our service offering. |
Identification and contact details Feedback you choose to provide us |
Legitimate interest |
Feedback (and related personal data) will be retained for 5 years. |
| To share your testimonials, reviews, experience and references on our Website and other social media (including LinkedIn) to promote our services to potential customers and Website visitors |
Identification details Professional information Photo’s and video’s Any information shared during and in your review |
Consent The consent you give is always free and you have the right to withdraw your consent at any time, free of charge, and without this having any negative implications for you by contacting us at: privacy@fourandfive.be. |
As long as your consent is not withdrawn. |
| To register your participation to any of our events, workshops or academies and to organize our events, workshops and academies. |
Identification and contact details Professional information Technical information As long as necessary to organize the relevant event, workshop or academy. |
Performance of a contract | As long as necessary to organize the relevant event, workshop or academy. |
| For direct marketing purposes (such as to send promotional emails about our services, functionalities, special offers, events, workshops, academies and other information which we think might interest you) and to share information about past events, academies and workshops. |
Identification and contact details Photo’s and video’s Professional information |
Consent or legitimate interest (as applicable) The consent you give is always free. You have the right, at any time and free of charge, to withdraw your consent and to object to the processing of your personal data for direct marketing purposes, by sending an email to: privacy@fourfive.be. |
As long as your consent is not withdrawn. For more details, reference is made to our cookie policy. |
4.5. Website-visitors, applicants, clients and participants of our events
Four & Five may process personal data of Website-visitors, applicants and clients for the following purposes:
| To comply with our legal obligations (including to respond to data subject requests, to respect your (consent) preferences, to adhere to our anti-money laundering and know-your-customer obligations to protect the rights of others). |
Identification and contact details Payment details Information regarding your visit and appointments (e.g. date and time) Any additional information you provide us or required to adhere to our legal obligations |
Legal obligation |
The retention term varies from as long as the duration of a Website-visit to as long as required by law. Your personal data will in any event be deleted ten (10) years after the expiry or termination of our (client) relationship, unless a longer retention term applies in accordance with applicable laws or deontological rules to which we are subject. |
|
To execute our business administration (such as to manage our (client) relationship and to address potential complaints). For more information about certain of our legal obligations please consult our general terms and conditions. |
Identification and contact details Usage information Payment details Technical information Information regarding your visit and appointments (e.g. date and time) Other personal data (this depends on the legal obligation involved) |
Legal obligation |
The retention term varies from as long as the duration of a Website-visit to as long as required by law. Your personal data will in any event be deleted ten (10) years after the expiry or termination of our (client) relationship, unless a longer retention term applies in accordance with applicable laws or deontological rules to which we are subject. |
| To register your participation to any of our events, workshops or academies and to organize our events, workshops and academies. |
Identification and contact details Professional information Technical information As long as necessary to organize the relevant event, workshop or academy. |
Performance of a contract | As long as necessary to organize the relevant event, workshop or academy. |
| For direct marketing purposes (such as to send promotional emails about our services, functionalities, special offers, events, workshops, academies and other information which we think might interest you) and to share information about past events, academies and workshops. |
Identification and contact details Photo’s and video’s Professional information Technical information Usage information |
Consent or legitimate interest (as applicable) The consent you give is always free. You have the right, at any time and free of charge, to withdraw your consent and to object to the processing of your personal data for direct marketing purposes, by sending an email to: privacy@fourfive.be. |
As long as your consent is not withdrawn. For more details, reference is made to our cookie policy. |
For more details about the retention period, you can always send an email to: privacy@fourfive.be.
5. Cookies
Our Website uses cookies and similar technologies. For more information, we refer to our cookie policy.
6. With who do we share your personal data?
Four & Five may share your personal data, as required for the purposes set forth in section 4, with:
- third-party service providers (such as IT service providers, security providers, suppliers, communication and other software providers or hosting providers);
- professional advisers (such as accountants or auditors);
- partners (such as third party (experts) involved in organizing events and workshops);
- affiliated entities;
- supervisory authorities; and
- third parties to whom we intend or choose to sell, transfer or merge (parts of) our shares, business or assets.
Upon request, Four & Five shall, as soon as possible after the request, inform you of the third parties with whom your personal data have been shared by providing you a more detailed list.
In addition, we may disclose your personal information if required by law, or if we believe in good faith that such disclosure is necessary to comply with a judicial investigation, court order or to defend or safeguard our rights.
Processors and sub-processors of Four & Five always act under the responsibility of Four & Five. We always ensure that appropriate protective measures are taken when we transfer your personal data to third parties. If Four & Five engages (sub-)processors, this will always be done in accordance with a data processing agreement that meets the requirements of the GDPR. We require all our (sub-)processors to take appropriate technical and organizational (including security) measures to protect your personal data. In the event we disclose your personal data as described above, we will implement appropriate safeguards to ensure the integrity and confidentiality of your personal data.
Your personal data will only be made available to (sub-)processors, staff and employees and other third parties on a “need-to-know” basis, limited to the extent necessary to perform their services.
7. Will your personal data be transferred to countries outside the EEA?
In principle, Four & Five does not transfer your personal data to third countries located outside the European Economic Area (“EEA”) unless you are located outside the EEA (and are visiting our Website, use our services or otherwise provide personal data from outside the EEA).
Additionally, it is possible that Four & Five – through its (sub-)processors – does transfer your personal data to countries outside the EEA. In this event, Four & Five will only transfer your personal data outside the EEA in accordance with the applicable data protection legislation and subject to appropriate safeguards.
Please contact us if you want further information on the specific mechanism(s) used when transferring personal data outside the EEA.
8. How do we protect your personal data?
Four & Five is committed to trying to make sure that your personal data is secure and makes reasonable and appropriate efforts to protect your personal data. We take appropriate technical and organizational security measures to ensure a level of security in accordance with the GDPR.
Four & Five has implemented measures to protect your personal data against destruction, loss, misuse, unauthorized alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. Please contact us if you would like more information on the specific measures taken by sending an email to:
privacy@fourfive.be.
Despite the above measures taken by us, you should be aware that there are always risks associated with sending personal data over the internet. The security and protection of your personal data can never be fully guaranteed, nor can we guarantee that unauthorized third parties will never be able to defeat those measures or use your personal data for improper purposes.
9. How long do we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes determined in section 4 of this privacy policy, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Afterwards it is still possible that your personal data can be found in our back-ups or archives, but they will no longer be actively processed in a file. Such back-ups or archives will be deleted automatically in accordance with our back-up and archiving policies.
The applicable retention periods are set out in the table under section 4.
10. What are your rights and how can you exercise them?
Within the limits defined in Articles 15-22 of the GDPR, you have the following legal rights in relation to your personal data:
- Right of access: you have the right to obtain confirmation from us as to whether or not we are processing your personal data, to access that personal data and how and why it is being processed, as well as to receive a copy of that data.
- Right of rectification: If you notice that we are processing incorrect or incomplete personal data about you, you have the right to request that it be corrected or completed.
- Right to erasure (“right to be forgotten”): you have the right to obtain erasure of your personal data in certain specific cases.
- Right to object: You have the right to object to the processing of your personal data on the basis of our legitimate interest for reasons relating to your specific situation.
- Right to restriction: You have the right to have the processing of your personal data restricted in certain specific cases.
- Right to portability: You have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable form, and to transfer (have transferred) that personal data to another controller.
You can exercise the above rights by sending an email to privacy@fourfive.be.
The exercise of these rights is in principle free of charge. Only in the event of unreasonable or repeated requests, we may charge a reasonable administrative fee. Four & Five will inform you of the applicable fee before charging it.
In your request, make sure to clearly specify which right you wish to exercise so we can help you as efficient as possible. Please note that in some cases we may require you to give more information about yourself to ensure that we are dealing with the correct person.
If you contact us to exercise your rights we will respond within one month. Exceptionally this may take longer (up to three months), but then we will inform you within one month of the reasons why.
If and to the extent provided for in the applicable data protection legislation, you have the right to file a complaint with the competent supervisory authority (in particular in the member state of your habitual residence, the place of work or the place of alleged infringement), if you consider that our processing of your personal data violates the applicable regulations.
In Belgium the competent authority is the Data Protection Authority (“Gegevensbeschermingsautoriteit”):
www.gegevensbeschermingsautoriteit.be
Drukpersstraat 35, 1000 Brussels, Belgium
+32 (0)2 274 48 00
contact@apd-gba.be.
We would, however, appreciate the chance to handle your concerns before you approach the authority, so please contact us in first instance.
11. Are there any third party links on our Website?
Our Website may contain links to third party websites and/or applications. Four & Five is not responsible for the content of these websites and applications and is not responsible for the privacy standards and practices of such third parties. We recommend you to read the relevant privacy policies of these third parties and their websites before you accept their cookies and visit their website to ensure yourself that your personal data is sufficiently protected. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these websites and/or applications.
12. Consent for disclosure
You acknowledge, confirm, and expressly consent that we may disclose your personal data if this is required by law, or if Four & Five determines in good faith that such disclosure is required in order:
- to comply with any pending judicial inquiry, judicial order or litigation pertaining to the Website, our (client) relationship or our service offering;
- to compel observance of the general terms and conditions of Four & Five;
- to respond to claims against Four & Five regarding personal data that violate any rights of third parties;
- to safeguard the rights, property and safety of Four & Five, its employees, staff and third parties.
Four & Five may disclose your personal data to competent police or judicial authorities or other official government authorities if Four & Five deems this useful or necessary, in its sole discretion, for the investigation of fraud, intellectual property infringement or any other harmful activity, or if Four & Five reasonably suspects that such activity may expose Four & Five or you to any liability.
13. Changes to the privacy policy
Four & Five may modify this privacy policy at any time. Any changes we may make to our privacy policy will be indicated on the Website and when proportionate and in line with the significance of the changes, may be notified to you by email or advised to you on your next Website-visit. The date of the last amended version is listed at the bottom of the privacy policy. Please review this privacy policy periodically to stay informed of changes that may affect you.
Amended versions of this privacy policy take effect ten (10) days after their publication on the Website, and/or other form of announcement and, if necessary, will always be submitted for approval if required under the GDPR, unless such modifications are necessary to comply with a legal requirement. In the latter case, such changes will take effect immediately.
14. Liability
If Four & Five has lawfully provided your personal data to a third party (other than a subprocessor), it will not be liable for the unlawful processing or use by that third party. Four & Five is in any case only liable for the damage caused by the processing of personal data if it did not comply with its specific obligations under the GDPR.
Four & Five’s liability is limited to the amount effectively recovered under its professional liability insurance policy for the damage causing event. If, for any reason whatsoever, no effective recovery is obtained under the professional liability insurance, the liability of Four & Five shall be capped at the amount of fees invoiced to and effectively paid by you for the relevant services (if any), with an absolute maximum of 500,000 euros. Four & Five shall in no event be liable for any special, incidental, indirect or consequential losses or damages (including loss of data). The foregoing exclusions and limitations shall only apply to the maximum extent permitted by applicable law.
You agree, to the maximum extent permitted under applicable law, not to hold Four & Five’s directors, contractors, subcontractors, representatives, appointees, lawyers, employees, and other auxiliary persons personally or directly liable for or in connection with the (performance of the) services provided by Four & Five, its lawyers or personnel. In this respect, you waive any tort claim against the aforementioned persons. Any (liability) claim for or in connection with the processing of your personal data (including any tort claim) will (may) be brought exclusively against Four & Five.
15. Applicable law and competence
This privacy policy shall be governed, interpreted, and implemented in accordance with Belgian laws.
The Antwerp courts (division Antwerp) are exclusively competent to decide on any dispute that may arise from the interpretation or implementation of this privacy policy, without prejudice to the consumer’s right to present a dispute before a competent court on the basis of a mandatory statutory provision.
Latest update: August 2024
